Chapter 11: Balance Sheet Instructor Manual
5. Shown below are paragraphs 8–10 of ARB 43, Chapter 7 on stock dividends.
Para. 8. The question as to whether or not stock dividends are income has been
extensively debated; the arguments pro and con are well known. The situation cannot be
better summarized, however, than in the words approved by Mr. Justice Pitney in Eisner
v. Macomber, 252 U.S. 189, wherein it was held that stock dividends are not income
under the Sixteenth Amendment, as follows:
“A stock dividend really takes nothing from the property of the corporation and adds
nothing to the interests of the stockholders. Its property is not diminished and their
interests are not increased . . . the proportional interest of each shareholder remains the
same. The only change is in the evidence which represents that interest, the new shares
and the original shares together representing the same proportional interests that the
original shares represented before the issue of the new ones.”
Para. 10. As has been previously stated, a stock dividend does not, in fact, give rise to
any change whatsoever in either the corporation’s assets or its respective shareholders’
proportionate interests therein. However, it cannot fail to be recognized that, merely as a
consequence of the expressed purpose of the transaction and its characterization as a
dividend in related notices to shareholders and the public at large, many recipients of
stock dividends look upon them as distributions of corporate earnings and usually in an
amount equivalent to the fair value of the additional shares received. Furthermore, it is to
be presumed that such views of recipients are materially strengthened in those instances,
which are by far the most numerous, where the issuances are so small in comparison with
the shares previously outstanding that they do not have any apparent effect upon the
share market price and, consequently, the market value of the shares previously held
Required:
(a)From a logical standpoint, evaluate the CAP’s argument involving situations where
market value of common stock should be capitalized in certain stock dividend situations.
(b)Do you see a possible “hidden agenda” here involving certain economic consequences
that the CAP was trying to bring about relative to stock dividends?